Inspections at MSW Landfills Original Content is from USEPA Telecourse APTI T – 021-01 “The Use of Federal Reference Methods in the Evaluation of Landfill Gas Emissions” by William T. “Jerry” Winberry, Jr. EnviroTech Solutions

Landfill

Landfill Gas Collection System Components Electrical power out Controlled emissions Gas collection header Final soil cap cover Recovery system Enclosed flare Landfill gas Gas collection wells

Landfill Gas Collection System Components Fill material Surface monitoring Ambient air monitoring Gas leaks Uncontrolled emissions Landfill gas Perimeter vents Groundwater monitoring well Leachate manhole

Reasons for Inspections of MSW Landfills Compliance determination Complaint investigation Source plan approval Review or renewal of permits Special studies

Pre-Inspection Procedures File review Regulation review Equipment checks

File Review Initial design capacity report Annual or 5-year NMOC emission rate report Permit to construct (P/C) and permit to operate (P/O) Collection and control system design plan

File Review Annual reports Landfill closure reports Control equipment removal reports Previous inspection reports Enforcement action: Complaints and notice of violation

File Review Enforcement action taken, orders of abatement, variance history Compliance test data Equipment malfunction reports SSM Plan and any events

Regulation Review Identify all rules that apply to the facility Review any references to the specific rules which are noted in the landfill file Be familiar with each standard and exemption

Equipment Check Hard hat Gloves Safety vest Respirator/dust mask Method 21 system route map Steel-toed safety shoes

Equipment Check Contd.: Safety glasses First aid kit Flashlight Field checklist Portable monitor (gas detector system) Digital manometer

Portable Monitor Obtain certified portable gas monitor Verify operating conditions and specifications Assemble and start-up instrument according to manufacturer’s instructions Leak check sampling system

Portable Monitor Contd.: Evaluate response factor (RF) with known concentration of certified methane gas Evaluate calibration precision with certified methane gas standard using zero gas or background as low calibration point Repeat two additional times

Portable Monitor Contd.: Calculate calibration precision Check response time during calibration precision evaluation Verify sample flow rate

Notify the Landfill Notify landfill of inspection so that relevant documents can be made available for review Obtain map and/or diagram of the landfill with elevations, wellhead locations, header system placement and control devices.

Pre-entry Look at landfill from neighborhood Take wide angle picture of landfill for file Talk to neighbors about activities at landfill

Pre-entry Where possible, drive around the outside perimeter of the landfill Notice any landfill odors? See any visible emissions? Litter in neighborhood which looks like it originated from the landfill?

Entry Enter by public access route Identify yourself, present your credentials Ask to meet with the site representative

Pre-Inspection Meeting Explain purpose of inspection and discuss any new rule changes Answer questions that the source personnel may have Identify equipment to be used in the inspection

Pre-Inspection Meeting Information Verify facility information Facility name, ownership Facility address, telephone number Facility contact name, telephone number Discuss safety procedures

Pre-Inspection Meeting Information Review Permit Verify that permit is current and posted that permit is for correct equipment that permit operating conditions are being met date permit issued design capacity information

Pre-Inspection Meeting Review permit specification from office to on-site List of equipment/wellheads installed or to be installed Emission limits to be met Changes/modifications to permit conditions Site-specific monitoring requirements

Pre-Inspection Meeting Operational Logs Historical emission records and self monitoring data available from past 5-years Monitoring and calibration logbooks

Pre-Inspection Meeting Operational logs for active collection systems Logbooks associated with well head monthly monitoring parameters: Temperature Gauge pressure Gas concentrations of: Oxygen Nitrogen

Pre-Inspection Meeting LFG control system operational logs for flares, co-generation facilities, gas turbines, or internal combustion engines Calibration, operation, and maintenance records Equipment “downtime”

Pre-Inspection Meeting Heat sensor operational records Continuous temperature recordings Compliance testing performed since last inspection LFG monthly gas flow rate Well concentration readings

Pre-Inspection Meeting Environmental Data Average wind speed for today (< 10 mph) Rain fall over last seven days Barometric pressure over last seven days

Pre-Inspection Meeting Sampling Grid Pattern Obtain from pre-inspection or create a sampling grid pattern over a map of the landfill, with parallel lines approximately 30 meters apart Start grid pattern at control device, then around perimeter of landfill, then into landfill with parallel lines

Walking route Landfill gas flare facility A

Physical Inspection of Landfill Start the on-site physical inspection of the landfill at the outer perimeter Acquire a “background/upwind” concentration of LFG using FRM 21 certified monitor

Physical Inspection of Landfill Observe visible emissions (VE) Haul road, flares, energy recovery systems Continue to control equipment and follow the grid pattern

Physical Inspection of Landfill Collection and control equipment, note Comparison between landfill records and visual inspection Observation of Leaks and maintenance Operations according to site-specific collection system design plan

Physical Inspection of Landfill Monitor surface of landfill with FRM 21 gas monitoring probe Position FRM 21 monitor with tip approximately 2-4 inches off ground Follow the grid route around perimeter of site, noting a reading every 30 meters. Record readings on field test data sheet (FTDS)

Physical Inspection of Landfill Enter the site according to the grid route map Take readings every 30 meters, until the complete landfill surface has been evaluated, using the grid route Any reading 500 ppm above background should be recorded on FTDS and marked with a flag

Physical Inspection of Landfill Monitoring surface of landfill Monitor any crack, hole, breach in the surface, and interface with undisturbed native soil Monitor around rocks and objects sticking out of the surface of the landfill for possible LFG emissions

Landfill Surface Cover Meter Reading - 15,000 ppm 0.1 L/min sample intake rate (minimum rate allowed for Method 21) Leak detector probe tip 1/4 in. dia. Landfill Surface Cover Leak

Landfill Surface Cover Meter Reading - 500 ppm 3.0 L/min sample intake rate (maximum rate allowed for Method 21) Leak detector probe tip 1/4 in. dia. Landfill Surface Cover Leak

Monitoring LFG Collection System As you monitor the landfill, note Any leaks heard coming from the LFG collection system Any broken header lines Any well heads broken and venting LFG

Monitoring LFG Collection System Elevated concentrations of LFG: Around horizontal or vertical well casings Venting from LFG well vaults Around connecting tubing etc.

Monitoring LFG Collection System Monitor extraction well parameters and compare to pre-inspection values Temperature Static pressure Gas concentrations Oxygen and Nitrogen

Monitoring Perimeter Gas Probes Monitor perimeter gas probes and compare to historical data Monitor perimeter water monitoring wells and compare to historical data acquired in pre-inspection meeting

Monitoring Selected Wellheads Temperature Gauge pressure Gas composition

Post-Inspection Procedures Perform single point calibration of FRM 21 gas monitoring system Compile field data sheets and observation notes

Post-Inspection Meeting Discuss deficiencies and inform owner of inspection results Advise source representative of any additional concerns that you might have Discuss corrective action to be taken for identified leaks

Example Format for Inspection Documentation/Report Prepare A written description of the landfill A diagram showing the location of control equipment, emission points, and tagging of any emission exceedances

Example Format for Inspection Documentation/Report A statement indicating compliance or violation for each emission point recorded Recommendations, if any, such as a source test or an engineering evaluation Assessment of fugitive emissions and other potential impacts